Brown’s remedial logic was internally ambiguous between colorblindness and integration.

Evidence

The Court in Brown offered somewhat incompatible explanations for its claim of psychological harm. On the one hand, it suggested that the harm to African-American students came from state-enforced segregation, which communicated a message of black inferiority; thus replacing racial criteria with color-blind criteria for school attendance would remedy the injury. On the other hand, the Court also said that African-American students were injured by lack of contact with their white peers. From this perspective, eliminating racial criteria would not suffice; racial integration of the schools was necessary, because only integrated education could be equal education. — G. Alan Tarr, Judicial Process and Judicial…, 2969

Categorization

• XREF: Tracks directly onto the course’s competing interpretations of equality — colorblind equal treatment versus integrationist equal opportunity.
• QUESTION: If the Court never resolved this tension, how have later desegregation and affirmative-action doctrines inherited it?